Garden of Eden Urban Farming
Nutritional labeling of fresh cut vegetables or living plants
2025
What is the best way to meet nutritional labeling requirements for fresh unpackaged foods?
For fresh unpackaged foods, the best way to meet nutritional labeling requirements depends on how the food is presented and sold. Here are the key approaches:
1. For bulk, consumer self-dispensing foods:
- Provide the manufacturer's or processor's label with the food[3].
- Display a card, sign, poster, or book at the point of sale with all required information[3].
- Use other notification methods at the point of sale, such as a sign stating "ingredients available upon request" with directions on where to find the information[3].
2. For unpackaged foods portioned to customer request:
- If prepared on-premise or in a satellite facility owned by the same owner, labeling is not required if no health or nutrient claims are made and ingredients are available upon request[3].
- For foods not prepared on-premise, provide labeling that includes the common name, ingredients, net quantity, manufacturer information, and allergen information[3].
3. For small businesses:
- Companies with fewer than 100 full-time equivalent employees producing fewer than 100,000 units of product per recipe per year are exempt from nutrition labeling, unless health or nutrient claims are made[5].
- These businesses can still include nutritional information voluntarily, using the Nutrition Facts panel format[5].
Examples
4. If choosing to provide nutritional information:
- Present nutrient information on a per-serving basis[5].
- Include mandatory nutrients such as calories, total fat, cholesterol, sodium, total carbohydrates, protein, vitamin D, calcium, iron, and potassium[7].
- Use nutrition-labeling software, commercial laboratory testing, or hire a consultant to determine nutrient values[5].
5. For all labeling:
- Use clear, simple language that accurately describes the product and its ingredients[4].
- Ensure all information is truthful and not misleading[4].
- Keep labels up-to-date with any changes to the product or ingredients[4].
By following these best practices, fresh food providers can meet nutritional labeling requirements while providing consumers with necessary information about unpackaged foods.
[1]: https://www.fsis.usda.gov/sites/default/files/media_file/2021-02/gb-7718-2011-part-ii.pdf
[2]: https://nwhort.org/wp-content/uploads/2014/10/FreshFruitLabelingManual-rev-0721141.pdf
[3]: https://www.lfchd.org/wp-content/uploads/2023/12/Labeling-Guidance-for-Foods-in-Retail-Establishments.pdf
[4]: https://www.itsallgoodsinc.com/insights/food-labeling-best-practices-to-stay-compliant-and-avoid-lawsuits
[5]: https://extension.psu.edu/food-for-profit-food-labels
[6]: https://www.fns.usda.gov/fs/produce-safety/best-practices-schools
[7]: https://blog.trustwell.com/food-product-labeling-and-packaging-101
[8]: https://fns-prod.azureedge.us/sites/default/files/Food_Safety_Produce_Best_practices.pdf
For fresh unpackaged foods, the best way to meet nutritional labeling requirements depends on how the food is presented and sold. Here are the key approaches:
1. For bulk, consumer self-dispensing foods:
- Provide the manufacturer's or processor's label with the food[3].
- Display a card, sign, poster, or book at the point of sale with all required information[3].
- Use other notification methods at the point of sale, such as a sign stating "ingredients available upon request" with directions on where to find the information[3].
2. For unpackaged foods portioned to customer request:
- If prepared on-premise or in a satellite facility owned by the same owner, labeling is not required if no health or nutrient claims are made and ingredients are available upon request[3].
- For foods not prepared on-premise, provide labeling that includes the common name, ingredients, net quantity, manufacturer information, and allergen information[3].
3. For small businesses:
- Companies with fewer than 100 full-time equivalent employees producing fewer than 100,000 units of product per recipe per year are exempt from nutrition labeling, unless health or nutrient claims are made[5].
- These businesses can still include nutritional information voluntarily, using the Nutrition Facts panel format[5].
Examples
4. If choosing to provide nutritional information:
- Present nutrient information on a per-serving basis[5].
- Include mandatory nutrients such as calories, total fat, cholesterol, sodium, total carbohydrates, protein, vitamin D, calcium, iron, and potassium[7].
- Use nutrition-labeling software, commercial laboratory testing, or hire a consultant to determine nutrient values[5].
5. For all labeling:
- Use clear, simple language that accurately describes the product and its ingredients[4].
- Ensure all information is truthful and not misleading[4].
- Keep labels up-to-date with any changes to the product or ingredients[4].
By following these best practices, fresh food providers can meet nutritional labeling requirements while providing consumers with necessary information about unpackaged foods.
⁂
[1]: https://www.fsis.usda.gov/sites/default/files/media_file/2021-02/gb-7718-2011-part-ii.pdf
[2]: https://nwhort.org/wp-content/uploads/2014/10/FreshFruitLabelingManual-rev-0721141.pdf
[3]: https://www.lfchd.org/wp-content/uploads/2023/12/Labeling-Guidance-for-Foods-in-Retail-Establishments.pdf
[4]: https://www.itsallgoodsinc.com/insights/food-labeling-best-practices-to-stay-compliant-and-avoid-lawsuits
[5]: https://extension.psu.edu/food-for-profit-food-labels
[6]: https://www.fns.usda.gov/fs/produce-safety/best-practices-schools
[7]: https://blog.trustwell.com/food-product-labeling-and-packaging-101
[8]: https://fns-prod.azureedge.us/sites/default/files/Food_Safety_Produce_Best_practices.pdf
Sample content description if desired
Label if used should show at minimum serving size, total calories and % RDA for major nutrients.
Standard label
Adapt as required to specific product.
State values as average by type not necessarily for specific package. Clarify that no specific claims regarding nutrition are made.
Pennsylvania State Extension overview
NOTE: Nothing on this page should be interpreted as legal advice. You should consult legal counsel regarding specific claims regarding contents or products.
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